Pre-amendment reassessment limitation bars late notices under the preserved regime, invalidating consequential reassessment for affected earlier asses...
Cash-sales explanations for bank deposits require documentary reconciliation; reassessment notice survived where effective response time was available...
Functional comparability in transfer pricing prevents ad hoc arm's length adjustments where functions, assets, risks and reliable comparables are unes...
Contingency expenses, exempt-income disallowance, and royalty benchmarking: unsupported adjustments were deleted under consistent accounting and trans...
Electronic transmission of summons and relied-upon documents satisfied Rule 13(3)(iii) read with Rule 13(11) and Section 13 of the IT Act, and email delivery of PDF RUDs was held valid; recording of reasons to believe under Section 8(1) PMLA was examined and upheld as based on perusal of RUDs and investigation material; the Adjudicating Authority must determine whether specific documents qualify as relied upon documents and, if so, order their supply and permit a two week supplementary reply, with aggrieved parties able to seek remedies under Section 26 PMLA.
Electronic transmission of summons and relied-upon documents satisfied Rule 13(3)(iii) read with Rule 13(11) and Section 13 of the IT Act, and email delivery of PDF RUDs was held valid; recording of reasons to believe under Section 8(1) PMLA was examined and upheld as based on perusal of RUDs and investigation material; the Adjudicating Authority must determine whether specific documents qualify as relied upon documents and, if so, order their supply and permit a two week supplementary reply, with aggrieved parties able to seek remedies under Section 26 PMLA.
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